Is Circumstantial Evidence Including Medical Testimony Enough to Prove Intentionally Inflicted Injuries to the Victim ?

In People v. Holmes, 246 Ill. App. 3d 179, 186 Ill. Dec. 558, 616 N.E.2d 1000 (1993), a divided Third District Appellate Court reduced defendant's first degree murder conviction of his infant son to involuntary manslaughter. The majority found that medical testimony that a "one-time" severe shaking of the infant as the cause of death was insufficient to demonstrate that defendant knew that his conduct created a strong probability of death or great bodily harm. Holmes, 246 Ill. App. 3d at 181. The third district, however, has subsequently rejected the Holmes court's analysis and instead has followed the holdings of Renteria and Rader. In People v. Ripley, 291 Ill. App. 3d 565, 226 Ill. Dec. 259, 685 N.E.2d 362 (1997), the third district affirmed a defendant's conviction for aggravated battery of a child. Stating that Holmes was "wrongly decided," the court reiterated the rules of Renteria and Rader and explained that "circumstantial evidence, including medical testimony regarding the severity of the injuries imposed, is sufficient to prove that the injuries were intentionally or knowingly inflicted, even where a defendant testifies that he did not intend to injure the victim." Ripley, 291 Ill. App. 3d at 569.